ML19260E091

Comments on Proposed Reg Guide 1.97,Revision 2:format Difficult to Read.Scope Should Be Same as ANS 4.5. Continous Recording Requirements Too Restrictive

ML19260E091
Person / Time
Site:	Diablo Canyon
Issue date:	01/21/1980
From:	Crane P PACIFIC GAS & ELECTRIC CO.
To:	NRC OFFICE OF THE SECRETARY (SECY)
References
RTR-REGGD-01.097, RTR-REGGD-1.097, TASK-OS, TASK-RS-917-4 NUDOCS 8002130332
Download: ML19260E091 (39)

Text

.

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Secretary of the Commission @ @s U. S. Nuclear Regulatory Commission Washington, D. C. 20555 #/ \.%

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Attention: Docketing and Services Branch Ch g, p <e. -

Re: Docket No. 50-275 Office cf the Secretay Docket No. 50-323 ro Dc: ken J, senice Branch e Diablo Canyon Units 1 & 2 Q) g, e

Dear Sir:

N Attached for your review and information are our comments to the proposed revision 2 to Regulatory Guide 1.97. Attachment A represents our general com-ments without regard to specific plant applicability, while Attachment B addresses the feasibility of design-ing and installing instruments meeting the proposed re-quirements at Diablo Canyon. The Attachment B comrnents were solicited by Mr. Victor Benaroya at the December 13 meeting with representatives of several utilities and the NRC Staff.

Very truly yours, s

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ATTACHMENT A r

COMMENTS ON REGULATORY GUIDE 1.97 REVISION 2 BY PACIFIC GAS AND ELECTRIC COMPANY These comments apply to the Regulatory Guide as written without regard to specific plant applicability. Comments on the feasibility of implementation at Diablo Canyon were submitted separately. The attached mark up of the standard has our comment numbers in the margin.

1. Our first comment deals with the format of the Regulatory Guide. As written, it is extremely difficulty to read and understand. We are aware of the circumstances which led to the Reg. Guide having a different scope than ANS 4.5. We think that this is unfortunate, and we feel that the Reg. Guide should either adopt the same scope as the standard (with possibly a separate Reg. Guide for instruments not within that scope) or else stand on its own.

2. Regulatory Position C.3 expands the definition of design basis accident events. Much confusion has been needlessly generated in this industry simply because the terminology is not consistent. While it is prudent to provide instrumentation for operational transients and faults of moderate frequency, it is not prudent to force fit them into existing definitions.

Both the Reg. Guide and the Standard have attempted to redefine design basis accident; we do not believe this should be done. The definition should be deleted; the scope does not depend on it.

3. Regulatory Position C.6 appears to be arbitrary. We realize that within the definition of Phase II, many instruments within the TMI-2 containment are still working and many are still required, but the atmosphere is no longer abnormal. If an instrument is now working there, it would not be expected to fail now as a result of a previously adverse environment.

The hardship that would be imposed en industry by upping the post-accident duration does not appear to be justified in view of the benefit that could be gained. We do not believe that single new failure would be found if every device was retested for a 200 day post-accident duration.

-2A-

4. Due to the various implementations of criteria in various plants, we believe that the requirements indicated for Table 1 Items 1, 2, 3, and 11 should be "per licensing committments" or some such statement rather than "per regulatory guide xxx"

5. Table 1 criteria 8 and 9 deal with the display. The requirement for continuous recording is too restrictive and does not take into consideration the purpose of the display. The requirement that the display be continuous is a valid one as it stands on its own. It does, however, rule out all printing recorders used for multipoint recording (over 3 points) . The devices print at an interval equal to the cycle time between points. The other half of the problem is the requirement to record everything. Indeed, many parameters should be recorded, but some needn't be. Recorders waste valuable control board space and spread the operator's field of attention over a large area to view a small number of parameters. We feel that flexibility of the type given in note 16 is ?ppropriate. We think that continuous records are mequired when the trcnsient response is such that useful information is lost by intermittant recording (e.g., containment pressure). Intermittant records should be allowed if the transient response time is greater than the recording interval (e.g. , incore thermocouples). Some parameters would be farcical to record (e.g. , valve position). Others would provide no additional information if recorded (e.g. , reactor coolant flow) . Recording should be required when trend information can be useful in monitoring the accident. We suggest the following changes to Notes 14 and 17.

14. Continuous Display. Intermittant displays such as data loggers and scanning recorders may be used for multipoint parameters if no significant transient response can occur inside the recording interval .

17. Recording for those parameters where trend or historical information is required to moniter the function.

6. On Table 2, the neutron flux fission counter should be deleted since any fission counter which can monitor this low range cannot survive normal operation.

-3A-

7. Reactor coolant flow may be used to monitor a critical safety functions' accomplishment, but it doesn't monitor the function of any safety system. Therefore, Type D should be deleted.

8. This comment mirrors a concern aluded to in Comment 7. It is important to properly define what it is that we are indicating. We think that it is important to differentiate between safety functions and safety systems.

The indication of these valve positions indicates the completion of a safety function - containment isolation. The system which causes this to occur is not being monitored at all. Hence Type D should be deleted.

9. The purpose for containment sump water level indicates that this instrument indicates a breach (Type C), and an inventory control (Type A). No Type B purpose is given. (We are not indicating Type A functions on this guide because that is plant specific.)

10. We question the purpose of rain feedwater flow as a PN4 function. We know of no accident scenario where main feedwater is supplied to the steam generator; indeed it is isolated out on anything other than a simple reactor trip.

11. We do not feel that safety valve position is a safety system function.

12. We agree that it is necessary to monitor condensate storage tank level to assure an adequate water supply. This moaitors the performance (capability) of a safety system. We do not feel that it monitors the response of the plant or the potential for breach of a release barrier.

13. We feel that monitoring of sump levels and space temperatures which are not actually used by the safety systums are only valid for defense in depth.

14. A number of functions or capabilities are listed which are not what is normally considered to be plant instruments but rather sampling and laboratory capabilities. While we do not question the need to have these capabilities, we do question them in this regulatory guide. We feel that permanent plant instrumentation and laboratory equipment and capabilities should be well separated.

, -4A-

15. Table 2 also contained meteorological instrunentation. Pag. Guide 1.23 defines these requirenents. Rather than provide detailed information here that may conflict with future revisions of Reg. Guide 1.23, a simple reference should be used.

We did not review Table 3, since it is not applicable to our current endeavors.

p,. e,%% 4% TO - (t l2 14 4 U.S. NUCLEAR REGULATORY CC 411SSICN e 2

..e 0FFICE OF STANCARDS DEVELOPMEiT December 1SH Y'f.ph[o#!V DRAFT REGULATORY GUIDE AND VALUE/ IMPACT STATERENT Division 1

%, , Task RS 917-4 Certact: A. S. Hintze. (3013 ta3-5013 PROPOSED REVISION 2* TO REGULATORY GUICE 1.97 INSTRUMENTATION FOR LIGHT-WATER-COOLED NUCLEAR PO%ER PLANTS TO ASSESS PLANT AND ENVIRCNS CONDITIONS DURING AND FOLLOWING AN ACCICENT A. INTRODUCTION Criterion 13, " Instrumentation and Control," of Appendix A, " General Design Criteria for Nuclear Pcwer Plants," to 10 CFR Part 50, " Domestic Licensing of Production and Utilization Facilities," includes a requirement that instrumen-tation be provided to monitor variables and systems for accident conditions as appropriate to ensure adequate safety.

Criterion 19, " Control Rocm," of Appendix A to 10 CFR Part 50 includes a h' g requirement that a control roco be'provided from which actions can be taken to '

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maintain the nuclear power unit in a safe condition under accident conditiens, g including loss-of-coolant accidents, and that equipment, includirg the necessary hN instrumentation, at appropriate locations outside the untrol m m be provided with a design capability for prompt hot shutdown of tie rea:ter.

Criterion 64, " Monitoring Radicar:tivity Releases," of Appendix A to 10 CFR Part 50 includes a requirement t& means be provided for monitoring the reactor D containment atmosphere, spaces containing compenents for recirculation of loss-N g of-coolant accident fluid, effluent discharge paths, and the plant environs 14 for radioectivity that may be released from postulate d accidents.

[ This guide describes a method acceptable to the NRC staff fcf complying Q with the Ccemissien's regulations to crovide instrumentation to xnitor plant variables and systems during and following an accident in a lignt water coolec 0 nuclear power plant.

"The substantial number of changes in this procesed revision has made it imprac-tical to indicate the changes with lires in the margin.

This regulatory guice and the associated vat. e/!nset stateremt are teirq issued in drsf t form to involve the pustic in the early stages of tre tevelet-ant of a re;ulatery ::sition in this a*ea. They have not received coeplete staff revtew, $ ave rot teen reviewed by tPe GC Kegulatory Re:uire ents Review Canittee, and do not represent an official N#C staff position.

A fR the value/i pact state-e9t.Public cements are beleg solicited on bath draf ts, the guide (inc?uding any ieslementation sc.ted C: rents on t'e valee/I tict sta:s-=mt svuld te 5:c; seiec by Sur:crtiig O ta. C:- ents e9 i s;;i in : - N:d . e mt to tre , .- * ; i rv Sf t'= *:mi s < iet U.3. *weiese h;d at:ry C: ni s sien, ~4miir;;:a, C. " ::'!:, it*:ati a: C ec.e t P- ' c fr *.: I ia:9 :s Requests for sirgle c:oias of draf t ;aices (=nien ay be reproeuced) or for place-ent en an automatic distribution list fcr sfrgle ccpies of fut.re draf t quices in sDecific divisions should be made in writing to tPe U.s. No. lear Regulatory Cc M ss mn. Wash'egton. 0.C. *555, Attention: Cirector.

Division of Technical Information sr.d "oci.; ment 0:ntro!.

paths, and the plant environs for radicartivity that may be released during and following an accident from a nuclear power plant subject to the following:

1. Section 2.0 of ANS-4.5 defines the scope of the standard as contain-ing criteria for determining the variables to be monitored b, the control room operator during and following an accident that will need some operator action.

Consideration should be given to the additional requirements (e.g., emergency planning) of variables to be monitored by the plant operator (licensee) during and following an accident. Instrumentation selected for use by the plant opera-tor for monitoring conditions of the plant is useful in an emergency situation and for other purposes and therefore should be factored into the emergency plans action level criteria.

2. In Section 3.0 of ANS-4.5, the definition of " Type C" includes two items, (1) and (2). Item (1) includes those instruments that indicate the

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extent to which parameters that indicate the potential for a breach in the containment have exceeded the design basis values. In conjunction with the parameters that indicate the potential for a breach in the containment, the parameters that have the potential for causing a breach in the fuel cladding (e.g. , core exit temperature) and the reactor coolant pressure boundary (e.g. ,

g reactor coolant pressure) should also be included. References to Type C instru-ments, and associated parameters to be reasured, in Oraft Standard ANS-4.5 (e.g.,

Sections 4. 2, 5. 0, 5.1. 3, 5. 2, 6.1, 6. 3) should include this expanded definition.

3. c+'on 3 of " a-4. de 'ne desi . bas s a .ider eve ts. In conf'.ti wit the sign as' ac dent even+ de nea+ d in .he , tar 3rd, y t se ent hat - e ex".cte to cur ..e or mor tic dur' g '. e 1 fe f nue1 j ar wer .; t and inci eb' are .ot 1 mit to oss .p er o .1 rfci ulatir pumpe trip ng the .urbi.e g . era + r se', is. tat on f .;e m ncond[ser, ..d los of .1 of site cwe sho ' d be nci ded.

4.

• Section 4.2 of ANS-4.5 discusses the various types of variables.

With regard to the discussion of Type D variables, Type 0 variables and instre-ments are within the sc0pe of Accident Mon:toring Instrumentation although they are not addressed in Draft Standard ANS-4.5. They are, however, along with those of an additional type, Type E, included in this regulatory guide.

(See Tables 1, 2, and 3.)

5. Section 6.1 of ANS-4.5 pertains to General Design Criteria for instru-mentation monitoring Types A, B, and C variables. In conjunction with Section 6.1, 6

instrumentation acnitoring Types 0 and E variables should also be included.

Noted applicable design criteria are identified in Table 1 of this regulatory guide.

F 6. ect $ 6. 2 of NS- 5 pe ainjs to tr durp ion that in .r ent4 io is qua fic< to f cti . I - conj ctic/ with Secti4n 6.1n , Ph ,e Ii tre en-tat n sb uld qu ified o fu. tion or t less tha 00py nie a har er me, se on ne or c .. pone . acc/ssab ityfIrrep{acemo6t re air ca be sti ied.

7. Sections 6.2.2, 6.2.3, 6.2.4, 6.2.5, 6.2.6, 6.3.2, 6.3.3, 6.3.4, and 6.3.5 of ANS-4.5 pertain to variables and variable ranges for monitoring. In conjunction with tha above sections, Tables 1, 2, and 3 of this regulatory guide (which include those parameters mentioned in the rbove sections) should be used in developing the minimum set of instr':ments and their respective ranges for accident-monitoring instrumentation for each nuclear power plant.

[ 8. Section 6.4 of ANS-4.5 pertains to specific design criteria for accident-monitoring instrumentation. In conjunction with Section 6.4, the provisions as indicated in Table 1 of this regulatory guide should be used.

D. IMPLEMENTATION This proposed revision has been released to ercourage public participa-tion in its development. Except in those cases in which an applicant proposes an acceptabic alternative method for complying with specified portions of the Commission's regulations, the method to be cescribed in the active guice 4*

reflecting public comments will be used in the evaluation of the following applications that are docketed after the implementation date to te specifieo in the guide: -

1. Preliminary Design Approval (PCA) applications and Preliminary Dup 11cate Design Approval (PCDA) applications.

2. Final Design Approval, Type 2 (FDA-2), applications and Final Duplicate Design Approval, Type 2 (FDDA-2), applications.

3. Manufacturing License (ML) applications.

4. Construction Permit (CP) applications except for those pcrtions of CP aoplications that reference standard designs (i.e., PDA, FDA-1, FDA-2, P00A, FCDA-1, F00A-2, or ML) or that reference qualified base plant designs under the replication option.

7

In addition, the NRC staff intends to implement part or all of this guide for all cperating plants, plants under construction, all PCAs and FDAs, all PDOAs and all F00As that may involve additions, elimination, or nodification of structures, systems, or cceponents of the facility after the construction permit or design approval has been issued. All backfitti.99 decisions in accordance with the positicas stated in this guide will be determined by the staff on a case-by-case basis.

The implementation date of this guide will in no case be earlier than April 15,1980.

0 e

0 e

4

• 9 8

Table 1 DESIGN CRITERIA 1 CRITERIA INSTRUMENTATION TYPES 2 A B C D E

1. y* 1. Seismic qualification per k; ' a ., : . 1. M .

yes yes yes no no 3 pu 2. Single failure criteria yes yes yes no no f* per %;"' " n :. _ _ ' . :: y, 9 dl* 3. Environmental qualification yes yes yes 4 yes no 5 per b 2;tx., :_ W 1:C0 4

4. Power source Emr8 CB7 CB7 Emr8 Emr8

5. Out-of-service interval a a a o to before accident

6. Portable no no no ll no ll no ll I

7. Quality assurance level 12 12 12 12 12 I F

8. Display type 13 Con 14 Con 14 Conti C015 0015

9. Display method Rec 18 Rect 7 pect7 Indts Indis,ts

30. Unique identification yes yes yes no no

.18 9, 11. Periodic testing per yes yes yes yes no:8 N ; _ ' n n,

S 1 iM U,

'Unless 01tferen specifications are given in Inis regulatory guice, the specifications in ANSI N320-1979, " Performance Specifications for Reactor h

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Emergency Radiological Monitoring Instrumentation," a:: ply to the high-range containment area monitors, area expoeure rate monitors in other buildings, effluent and environmental monitors, and portable instruments for measuring g radiation or radioactivity.

V 2 Type A - Those instruments that provide information raquired to take preplanned 1 manual actions.

Type B - Those instruments that provide information to monitor the process of acccmplishing critical safety functicns.

Type C - Those i istruments that indicate the potential for breaching or the the actual braach of the barriers to fission product release.

Type 0 - Those instruments that indicate the performance of indivicual safety systems.

Type E - These instruments that provide information for use in determining the magnitude of the release of radioactive materials and for continuously assessing such rcleases, for defense in depth, and for diagnosis.

3 Radiation monitors should meet the requirements of ANSI N320-1979, Section 5.11 and/or Section 9.1.15, as acpropriate. ,

4See paragr3.cr. 5.3.6 of Draft Standard ANS-2.5.

(Footnotes continued}

9

Footnotes continued for Table 1

'Qualifiec to the conditions of its operation and, for radiation monitors, ANSI N320-1979.

SEmergency power source.

7 Critical Instrument Ous - Class 1E Power.

aParagraph 4.11 " Exemption," of IEEE Standard 279-1971.

SBased on normal Technical Specificaticn requirements ca cut-of-service for the safety system it serves.

10Not necessary to include in the Technical Specifications unless specified by other requirements.

11 Radiation monitoring outside containment may be portable if so designated in Taoles 2 and 3.

12 Level of quality assurance per Appendix B to 10 CFR Part 50.

18 Continuous indication or recording displays a given variable at all times; intermittent indication or recording displays a given variable periodically; on-demand indication or recording displays a given variable only when requested.

A$ 14 C : - t ' - ~ -: ' ; ;, ' ., . -

15 Indication on demand.

16Where trend or transient information is essential to planned operator actions.

$$ 11r =-1 --

1sDial or digital indication.

1* Effluent release monitors require recording, including effluent radioactivity monitors, environs exposure rate monitors, and meteorology monitors.

2oRadiation monitors should be periodically tested in accordance with the f requirements of ANSI N320-1979.

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10

Table 2

. PwR VA*!aetts Measured Variasle Range Type Purpose

. CORE Core Exit Temperature 150*F to 2300*F 8,C MS-4.5, Section 5. 2. 3.

To provice incere tee.:erature seasurements to icentify localized hot areas. (Approximately 50 seasurements)

Control Rod Position Full in or not 0 To provide positive indication that full in the control recs are fully insertec.

(Minisca 5 cays after accicent) i Ih Neutron Flum 1 c/s to 1% power E MS 4. 5, Section 6. 2.2.

For indication of a;oroaca to

.. . criticality.

REACTOR CCOLMT SYSTE.'i RCS Hot leg Teeper* 150*F to 750*F 8 MS-4. 5, Section 6.2. 3.

ature To af d in determi sing renc*:r syste a subcoolinJ and to orovi:e indication

• of natural circulation.

RC5 Cold Leg Terper- 150*F to 750*F 8 MS 4.5, Section 5.2.3.

ature To provide inoication of natural circulation; to provice inous f:r heat balance calculatfors; to provice direct incicatien of !*.5 injection.

RCS Pressure 15 psia to 4000 8,C MS-4.5, Sections 6.2. 3 anc 5.2.4

• psig For indication of an ac:tce t and to indicate

• Pat actions nus :s

. taken to mitigate an event.

Pressurizer' Level Bottom tangent to 8,0 MS-4. 5, Section 6.2. 3.

top tangent To assure pr:cer cceration of tne pressurizer and to assure safe operation of nesttes. It is also used in cenjunction witn changes in ree tor cressure to ceterstne leak and void si:es.

Cegree of Succcoling 200*F subcooling to E For Indication of naigin in ::re 35'F st.permeat cooling and the eetc for emergency coolant accitions or rec.ctices as

, the margin Cnanges sno to Cowiete the necessity to consult steam tables.

11

Table 2 (Continueo)

Measured varianle Range Type Purpose REACTOR CCCLANT SYSTE.1 (Continued)

Reactor Coolant Lcop 0 to 12C7. ]I:Eign~ B,[ To provide Indication that the core

'N Q Flow -12% to 12%)) fic=' is being cooled.

Primary System Safety Closed-not closed B,0 By these ressurements t5e ccerator Relief Valve Positicns knows if there is a cath c;en for (including PCRV and loss of coolant and that an event ecde valves) or Flow may be in progress.

Through or Pressure

- In Relief valve Lires I

i Ridiation Level in 10 pCf/cc to 10 CI/cc C ANS-4.5, Section 6.3.2.

Primary Ccolant Water For early incication of fuel

.. cladding failure anc estimate of extent of camage.

f CCNTA!M'ENT Contaicsent Pressure 10 psia pressure B,C ANS-4.5, Sections 6.2.5, 6.3.3, g to 3 tires cesis, pressure 2 for 6.3.4, and 6.3.5.

To incicate tr.e integrity of tr.e concrete; a t'ces primary or sec:neary systes cres-design prestwre - sure boundaries; to in31cate t?e for steel potential for leakage fe:n the contain ent; to indicate 19tegrity of the containment.

& Centainrent At.,os- a0*F to 4C0*F E For indication of tne perfor-a ce phere Tetperature of the containme9t c:oling syste, and acequate misin;.

e Containment $ cro;en 0 to 10% B,C ANS-4.5. Sections 6.2.5 cc 6.2.5.

Concentratica (capante of For indicaticn of t. e nees fc ano operating frem to measure tre :erfor acce of tne 10 psia to containment nycregen recs siner.

maximum design pressurea )

' Design fic - tre nam hum f1:w anticicated in cor al creration.

,'Cesign sressure - tnat value corres:cscing to ASME coce val es tnat are catained at or telow c:ce-411o.431e material casign stress values.

12

Taele 2 (Continued)

Measured Variable Range Type Purpose CCNTAlvCNT (Continued) 4 Containment Isola- Closed-not closed B,[ ANS-4.5, Section 6.2.5.

B tion Valve Position i To indicate the status of contain-F.ent isolation and to Drovide information on the status of valves in process lines that j

could carry radioactive materials out of containment.

f Y Containment Suro ,

Narrow range >.swo). [C ANS-4.5, Section 6.3.3.

• Water Level Wide range (tottes For indication of leaca;e within of contairrent to the containment and to ensure 600,0CO ;allon adequate inventory for performance level equivalent) of the ECCS.

High Range Contain- 1 to 10' R/hr 8,C To help identify if an accident cent Area Radiation (60 kev to 3 MeV has degraded ceyond calcalated photons with :2 3 values and to indicate its magii-accuracy for tude to determine action to photons of 0.1 to protect the puolic.

3 Fev)(10' R/hr for photons is approxt:ately equivalent to ICs j

rads per neur far betas and photons]

SECCNDARY SYSTEM Steam Generator From atemescheric 0 For indication of inte;rity cf t.*e Pressare pressure to 2 3 secondary system ard an irefcaticn e above safety value of capability for cecay r. eat settin2 r . oval.

Steam Generator Level Frc.m tute sheet to D For indication of integrity of the a separators secondary system and an incication of capability for cecay neat removal.

Auxiliary Feeewater 0 to 11C% design D To indicate an ade vate source of Flow flowl water to each steam generator u:en loss of main feecwater.

U w N " o t- Flow 0 to 110% ce1 Ma f 5 M -> % nm Pr"* - - of riow' water to each steam generator.

13

Table 2 (Continued)

Feasured Variacia Range Type Purpose SECCN0aRY SYSTEMS (Continued) pi e Safety / Relief Valve Closed-rot closed 8 To indica- 'ntegrity of seconeary 1i Positions or Main system (vis vis pipe cress).

Steam Flow Radioactivity in 10*' to ICs pCf/cc E To Indicate leakage frem the Condenser Air Xe-133 calibration primary to the secorcary system Removal Systes and measure of neole gas release rate to atmosphere.

,. Radioactivity in Efflu- 10*' to los pCf/cc E An indication of release frers the ent from Stean Gener- (alternatively, secondary systen and easure of j ator Safety Rolfer ancient packground noble gas release rate to atmos-

% Valves or Atmos;neric Dump Valvas to 2 Cl/sec/ W tn)

Xe-133 calibration phere. .

AUXILIARY SYSTEMS .

Csntainment Scray 0 to 11C% design D For indication of system c;eration.

Flow flowl Flow in HP! Systes 0 to 110% cesign For indication of systes cceration.

Q flowl D

Flew in LPI Systes 0 to 11C% design D for indication of systes cceration.

flown Emergency C:olant Top to tottom D To determfre the amount cf wate-g Vater Stora;e Tans Level discharged by t.9e E!*5. This provices tr.cication of t.e atu-e of the accident. ircicatien cf ..e performance of tre E" 5, a*c irci-c:tfon of tne c.ecessity (cr cperator action.

p Condensate Storage Plant specific g (For those plants wPere the c:n-h Tant Level ~ densate storage tand is the crin-ctpal source of au111ary feecwater.)

To ensure water suco1y for aut-If ary fece,ater punos.

Accumulator Tant Top to bottes D To indicate = nether eme tants 9 ave Level injected to the reactor c:alant

, system.

14

Table 2 (Continued)

Measured variante Range Type Purpose *

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AUXILIARY SYSTEMS (Continvec)

Accumulator Isolation Closed-not closed D To Indicate state of the isolation Yalve Positions valves (per Regulatcry Guice 1.47).

RHR Systen Flcw 0 to 110% design D for Indication ec' system operatien.

flow 3 RHR Heat Exchanger 32*F to 350*F D For Indication of sysles operation.

Out Temperature j Component Cooling 32'F to 200*F D For indication of systes cperation.

4 Water Terperature Cceponent Coolleg 0 to llc % design 0 For indication of systes operation.

Water flow f1cw3 -

0 Ficw in Ultimate Heat Sink Locp O to 11C% design ficw3 D For Indication of system operation.

Temperature in Ulti- 30*F to 150*F 0 For Indication of system c:eration.

cate Heat Sink Lo:p Ultimate Heat Siek Plant specific 0 To ensure adequate source of

, Level cooling water.

• Heat Remevai by the Plant specific 3 To ir.dicate system c:eration.

Contain.ow Fan e Coolers 8eric A:fd Cp.arging 0 to 11C: design 5 To provide incication of reactor Flow flow 3 cooling and inventory control in orcer to maintain aceouate c:ncen-tration '1r shutcewn t argin.

Letdown Flcw 0 to 11C% design D For indication of react:r coolant flow 8 f nventory control and toren concen-tration control.

p) Sun Level in Spaces of Couictent Requireo To corres:ending level of safety yE To ,onitor envi,,nnentai concitiuns of equipment in closed s: aces.

for Safety equipment failure RACwASTE SYST!.95 Hip '. eve l h :ic30*'ve ':0 te cott:1 1 Avail 3;te v3 M e tJ St:re ;ritary Liould Tann Le.el c:olant.

15

Table 2 (Continued)

Measured variable Range Type Purpose ,

RACVASTE SYSTEMS (Continued)

Radioactive cas Hold- 0 to 15C% of E Available capacity to store waste up Tank Pressure design pressure s gases.

VENT!!.ATICN SYSTEMS Emergency ventilation Open-closed D To ensure proper ventilation under Daeper Position status accident conditions.

p$

g Tempe ature of Space in vicinity of Eauio-30*F to 120'F [h To monitor envircr.sental conditions of equipment in c1csed spaces.

sent Required for Safety PCwER SUPPLIES Status of Class IE Voltages and 0 To ensure an adequate seurce of Power Supplies and currents electric power for safety systems.

i Systems Status of Non-Class Voltages and E To indicate an adecuate source of IE Power Suppites currents electric power, and Systems -

RADIATION EXPC53 5 RATES IN5!CE BUILC N S CR AREAS WERE ACCIis 15 e REqu! RED TO SEUICE SAFETY-RELATI3 (Cu!PPENT Radiation Ex:osure 10*' to 10* R/hr E For ceasure-ent of hign-*anqe h Rates for photons radiation execsure rates at sartoes locations.

(permanently installed monitors)

AIR 2CRNE RADICaCTIVE MATERIALS RELEASED 7 FRCH THE plA.*f A Effluent Radioactiv- (Norwal plus E MS 4.5 Section 5.2.6.

ity - Noble Cases accident range To provide operator ith informa-

'\

+

for noble gas) tion regarding release of racto-active ncole gases on centinuous

. Containment 10*' to 10s uCi/cc basis.

Xe-133 calleration Provisions should te made to monitor all

. Secondary 10-7 to 104 wCl/cc potential ;atneays for release of qiseous Containment Xe-133 calibration radioactive materials to tne envir:ns in (Reactor shield conformanca witn Cereral Cesign C.-iterien 64 building annalus) Note: Monitoring of incivicual eff) ent streams only is recuired wrere sucn streams are released oirectly to the environment If t o or ore streams are ccecined ocior to release from a CO f*on dis;rar e otint, onit:r-s; f t , :: :. es .t- ,- <5 Considered to ?9f*. **d :s.dat .*

nis S.sae pr:. :c: 1..- . .;r  ;

nas a ran;e 4:ec; ate to easure teorst-Case releases.

16

Table 2 (Continued)

Measured variante Ranc* Type Purpose AIR *0R'et RA0!0 ACTIVE MATERIALS RELDSE3 FRCM THE PLANT (Continued)

.Auxilfary Building 10-' to 108 pCf/cc including butiaings Xe-133 calibration -

containing primary '

systes gases, e.2 ,

waste gas decay tant

.0ther Pelease 10-' to 108 wCf/cc Points (including Xe-133 calibration Np fuel handling area

• if separate frez (permanently

( auxiliary building) installed monitors)

N k Effluent Radfoattiv-

{ty - High-Ran;e 10-8 to 108 pCf/cc E To provide the ccerator with information regarsirg release of Radionalogens and (permanently radioactive hateger.s arc articu-O Particulates installed lates. Continuous collection monitors) cf representative sa.rof es folic =ed by monitoring (-easure-ents) of

h. saeples for ractenalegens anc for particulates.

{

Environs Radioactiv- 10-e to 108 R/hr E AN5 4.5, Sectica 6.3.2 fty - Exposure Rate (60 key to 3 Fev) For estimating release rates of radioactive materials re? eased (permar.ently during an accicent frei .n :eati-

, 3 installed fled release cates ( ot ::<ere:

g ronitors) by ef fluent monitors) - c:nties :vs readsut caoanility. (;s:rsit ateiy J , 16 to 20 locati ns - site ce:en-dent.)

Environs Radicactiv- 10-' to 10*8 wCt/cc E For estimating release rates of ity - Radfohalogens for both radio- radioactive c.aterials releases and Particulates halogens and during an acci:ent fr:s unicanti-particulates fled release paths (rot coverec by effluent menitors). Continuous (perrt.ently collection of representative installed samples follcwec ey 9:nitoring samplers) (measurenents) of the savoies.

(Approximately M ts 23 locatiens -

site desencent.)

17

Table 2 (Continued) .

Measured Variable Range Type Purpose A!RERNE RADICACTIVE PATERIAL5 RELEASE 3 FROM THE PLANT (Continued) 1 Plant and Environs Mich Rvea E Ouring and fo11 ewing an accident, Radioact'vity 0.1 to lui R/hr to monitor radiation and air:orne (portante instruments) pnotons radioactivity concentrations in 0.1 to 10* rads /hr many areas througnout tre facility betas and low- and the site envirens =nere it is energy photons impractical to install stationary monitors capable of covering coth normal and accident levels.

100-channel E Ouring and following an accident, .

gamma-ray to rapidly scope the co cosition spectrometer of gamma-emitting sources.

POSTACCICENT SAMoLING CAPABILITY Primary Coolant As required based E AN5 4.5, Section 6.3.2.

Sumps on Regulatory To provide means for safe and Containment Air Guide 1.4 quide- convenient sarpling. These l lines provisions should incluce:

p .

PCSTACCICENT A.ALYSIS N 1. garaa-ray E 1. Shielding to maintain radiation W CAPA31LITY (CN SITE) spectrum doses ALA U.,

2. pH 2. Sa ple containers .ith c:ntairer-

3. hydrogen sampling pcrt connector co cati-4 oxygen bility,

5. baron 3. Capasility of sa.rs11rg u cea L prirary syste9 sressare ano negative pressee, i), 4. Handling and tra.is: Ort ca:ati-g

• 5.

lity, and Pre-arrangement for analysis and interpretation.

0 gf) NETEOROLCGY

\ Wind 01rection 0 to 350' (:5* E For de termining ef f!uent trans: ort N}

accuracy with a deflection of 15*,

direction for emergency plannirs, dose assessment, and source asti-Starting speed mates.

0.a5 mps (1 epn))

O 18

Table 2 (Continued)

Measured Variante Range Type Purpose METEOROLOGY (Continued) ,

Wind Speed 0 to 30 ros (67 E For determining effluent trsvel mph) (20.22 mas speed and dilution for emergency (0.5 roh) accuracy planning, doses assesseents, and 13 g for wind speeds source estimates.

s less that 11 cas

.(25 ron), with a starting thres-hold of less than 0.45 mps (1 ech))

Temperature -60*F to 120*F E For determinirs nature or precipitation (20.9'F accuracy) and ground deposition for etergency planning.

Vertical Temperature -9'F to +9'F E For determining effluent diffusien Difference (10.3*F accuracy rates for emergency planning, cose

! per 164-fcot assessments, and source estiestes.

h- intervals)

Precipitation . Recordir.g rain E For determining ef fluent trans: ort gage with range and grcund ccposition for eterge.9ey

[ planning.

sufficient to ensure accuracy of total accumu-1ation within 10%

of recorded value

- 0.01" resolution 42- .

O e

19

ATTACHMENT B COMMENTS CN THE FEASIBILITY OF APPLYING REGULATORY GUIDE 1.97, REVISICN 2 TO DIABLO CANYON POWER PLANT PACIFIC GAS AND ELECTRIC COMPANY On December 13, 1979, we met with the NRC to discuss the feasibility of designing and installing instruments meeting the requirements of proposed Revision 2 to Regulatory Guide 1.97 at Diablo Canyon. The following comments specifically address that feasibility. It is to be understood that these comments only address feasibility; they are not necessarily our total comments on the Regulatory Guide. Comments on the guide itself are in a separate document.

In that context, these comments address Table 2 "PWR Variables," and Table 1,

" Design Criteria", as it applies to Diablo Canyon.

General Comments:

It is important to note that while individual devices may be quite feasibly added, the cumulative additions may be impossible with our existing control room. There are several issues involved here.

When the issue of post accident monitoring first came up af ter TMI, our initial reaction was to supply a separate post accident monitoring panel.

It was intended that this panel house all of the recorders and high level readouts needed after an accident. After much discussion, we have concluded that this is not the best thing to do. When an abnormal event occurs, it is most important that the operator use instruments that he has a working familiarity with. These instruments are on the control board and are laid out in a logical, systematic order with which he is familiar. When he is required to react, it would be most imprudent to ask him to leave the board and go to a PAM panel. This is not to say that a PAM panel is unacc stable. 'Ihere are certain parameters (e.g., containment hydrogen or water level) that he doesn't normally use which could be mounted there.

Reams of paper could be produced discussing this point and all of the ramifications, but the bottom line is that we do not feel that it is legitimate to use the existence of a new PAM panel as a justification for adding as many instruments as we crn fit in. We do not believe that any

-2B-parameters used for normal operation can be put on the PAM panel if we expect the operator to use them properly. Therefore, tFs overall feasibility of adding control room instruments may be more limited than individual feasibilities.

We have a particular problem with recorders. They require huge amounts of control board space. Every type A, B, or C parameter requires at least two recorders per loop to meet the Regulatory Guide. Relief from that requirement is critical. There are two changes that could help. The first is to eliminate all recorders except those needed to provide historical or trend infornation to the operator. Many of these parameters are not. The second change is to allow a single recorder for any parameter. Our current method is to provide one indicator for each redundant channel and a recorder which can be switched between them to provide trending information.

Another area which we have problems with is radiation nonitoring.

We have a complete radiation monitoring system. The racks are full.

The new instrunents we cre adding will not be a part of that system. We are providing limited capability in our PAM panel. If the number we add is large, we run into problems. The steam line relief valve monitors alone would overextend our capabilities. If we are asked to extend the ranges of our existing equipnent, this will entail new instruments for which we will have to provide locations. We do not know that we have the room in our control room for the additional racks which would be required.

These problems are compounded by the fact that our cable spreading room is full. We can add neither new conduits nor new racks. Our racks are below the control room in the cable spreading room. This makes our control room very compact, but it has caused extreme cable spreading room problems.

About the only options we can see involve running conduit outside the building along the side to a roof entry. The impact on our suspended, lighted ceiling could be disasterous, to say nothing of the architecture of the room (which we realize is insignificant in these considerations) .

We have a problen with the requirement to environmentally qualify the Type D instruments. Almost all of these are presently not qualified, but are outside of containment and could be subject to low level elevated environments (2000 F @ atmospheric pressure) . This requirement will force wholesale replacement programs.

-3B-Finally, we are totally unable to produce qualifications for instruments for '200 day post accident operation.

With those general comments aside, our variable-by-variable status and feasibility is as follows:

Variables Core Exit Temperature Type: B, C Range: 1500F to 23000F Diablo 1000 F to 700 F The incore thermocouple system is neither environmentally nor seismically qualified. Qualification would involve the replacement of the reference junctions and possibly some wiring and connections inside containment. The physical arrangement does not lend itself to seismic testing without mocking up some part of the core assembly. Separation, if required to meet single failure criteria, would involve extensive redesign of the system and the reactor vessel.

Readout in the control room is presently 100-7000F, using a switchable indicator. Additionally, computer readout is from 0-1650 F. It would be feasible to add strip chart recorders which could trend several points per recorder, with appropriate switching to select points, logging recorders could provide more points, and 50 points could be accommodated, but the greater the number of points, the less visible are the trends. I don't think that more than about 6 points are reasonable to trend. The recorder range could be 0-2300 F without najor problems. Unfortunately, our stainless steel sheathed thermocouples are not capable of withstanding temperatures above 16500 F for extended periods.

If this is unacceptable, the entire system would have to be redesigned to incorporate inconel thermocouples.

Variable: Control Rod Position Type: D Range: Full in or not full in. Diablo: Full range indication The digital rod position indication system has electronic racks inside containment which manipulate and multiplex position signals. It would be totally unreasonable to move them to outside the containment (if for no other reason; there aren't enough spare penetrations) and it would be virtually impossible to environnentally qualify them. They do provide the required indicatf an.

-4B-Variable: Neutron Flux. Type: E Range: 1 c/s to 1% power. Diablo: 1 c/s to 10 6c/s (source range)

This parameter exists, but it does not have a fission counter.

I have been informed that a fission counter with the low range required would not sur/ive normal power pcwer operation and, therefore, cannot be used.

Variable RCS Hot Leg Temperature Type: B Range: 1500 F to 750 F Diablo: 0 F to 7000 F This parameter exists, and the recorder range could be changed, if required. We have the standard Westinghouse 4 loop configuration with only one hot leg wide range RTD per loop. Single failure criteria would have to be met by diversity. If mutually redundant RTDs were required on each of the 4 loops, we would have to add four new instrument loops and re-hydro our reactor coolant system.

Variable: RCS Cold Leg Temperature Type: B 0

Range: 1500 F to 750 F. Diablo 00 F to 700 F Same comments as given for hot leg temperature above.

Variable: RCS Pressure Type: B, C Range: 0-4000 psig Diablo: 0-6750 psig (being added) 0-3000 psig No changes required.

Variable: Pressurizer Level Type: B, D Range: Bottom to top tangents, Diablo: See below The Diablo pressurizer level is a wide rangt device which doesn't extcnd from tangent to tangent, but meets the basic intent. Three separate indicators are provided with one recorder which can be switched between them.

Installing a redundant recorder adjacent to the existing one would be impossible without major control board redesign.

-5B-

. Variable: Degree of Subcooling Type: E Range: 2000 F sub to 35 0F superheat Diablo: -40 to +2000 F subcooling (being added)

No changes.

Variable: Reactor Coolant Loop Flow Type B, D Range: 0 to 120% Diablo: 0-120%

-12% to +12%

There are 3 flow indicators on each of 4 loops, a total of 12.

We do not record reactor coolant flow. We feel there is relatively little value in recording this variable. If this is required, space which does not presently exist would have to be added to the control board. We do not know how we would accomplish this without major modifications.

It would be virtually impossible to add low flow and reverse low flow indication at Diablo Canyon. A total redesign of the reactor coolant system would be required. Certain methods have been suggested which would generate differential pressures on the order of 1" H20. Such a low differential as a valid reading would be impossible to detect with any instrumentation capable of standing the system pressures involved, to say nothing of the environment.

The only devices that I could find for such a low DP had ratings on the order of magnitude of 25 psig.

Variable: Primary System Safety Valve Type: B, D and PCRV position Range: Closed, not closed. Diablo: Safety-Acoustic (being added)

PORV Limit Switch These parameters are not recorded, and we do not think they should be.

They also are not redundant on each valve. Single failure criteria can be met by observing relief tank parameters.

Variable: Radiation Level in Type: C Prinary Coolant Range: 10 Ci/cc to 10 C1/cc Diablo: 101-106 CPM

-6B-If a single sample point with redundant off-line monitors outside containment is acceptable, we can provide this indication, assuming the monitors are available. Our existing gross failed fuel detector does not have the required range. Redundant recorders would have to be added in the control room.

Variables Containment Pressure Type: B, C Range: 10 psia to 3X design Diablo: 5 to +55 psig 0 to 200 psig (being added)

The monitors that go below atmospheric pressure have indicators but not recorders. Again, space Irmitations make this a very difficult addition to the control board.

Variables Containment Air Temperature Type: E Rance: 0 400F to 400 F Diablo: 600 F - 120 F This variable is not indicated in the control room. The range could be expanded and control room indication provided with some work assuming space could be found.

Variable: Containment Hydrogen Type: B, C Range: 0-10% Diablo: 0-10% (being added for January 1981)

No change required.

Variable: Containment Isolation Type: B, D Valve Position Range: Closed-not closed. Diablo: Limit Switches These parameters are not recorded and they are not redundant.

Check valves and similar valves have no indication. Any of these changes could be extremely dif ficult.

-7B-Variable: Containment Sump Level Type: B, C Ranger Narrow - Sump Diablo Bottom of sump to Wide - Containment to flood level 600,000 gal. Botton of containment to 600,000 gal.

(being added for January 1981)

The narrow range sump level is indicated but not recorded. Again, space limitations make this a very difficult addition to the control board.

Variable Containment Radiation. Type B, C Range: 7 1-10 R/hr. Diablo: 1-107 R/hr. (being added for January 1981)

No change required.

Variable: Steam Generator Pressure Type D Range Safety setting to +20%. Diablo: 0-1200 psig (= 109% of top safety)

If we increase the range, we will affect the accuracy, and thus the safety function of the parameter. We would prefer not to do this.

Variable: Steam Generator Level Type: D Range: Tube Sheet to Separator Diablo: See below our wide range level stops about 6 feet short of the separator, but covers the entire useful range of the steam generator.

Variable: Auxiliary Feedwater Flow. Type: D Range: 0-110% of design. Diablo: 0-136% of design These are not environmentally qualified devices. Otherwise, no change is required.

-8B-

, variable: Main Feedwater Flow Type: E Range: 0-100% of design Diablo: 0-117% of design No change required.

Variable: Safety / Relief Valve Type B, D Position or Main Steam Flow Range: Closed-not closed Diablo Main steam flow No change required.

Variable Condensate Air Ejector IP

• Radiation Range 10-7 to 10 5 Ci/cc. Diablo: 10-6 to 10-3 Ci/cc The existing monitor cannot be nodified to handle this range change, but assuming a suitable monitor is available, it can be installed with little difficulty. The problem with the readout is given in the general comments.

Variable: Steam Generator Relief Type: E Valve Radiation Range: 10~7 to 105 Ci/cc Diablo Ibne It would be virtually impossible to monitor the relief valve piping.

The size of an inline device would be prohibitive. An off-line device would fill with water. If we condense the steam and measure the water, we lose all noble gases. Assuming that we could use an area type monitor above the effluent, such a monitor could be added (actually a minimum of 4 monitors would be required due to the diverse locations of the 4 loop reliefs.)

Variables: Containment Spray Flow Type: D HPI Flow LPI Flow RHR Flow Component Cooling Water Flow Range: 0-110% of design Diablo: 0-110% or better

. -9B-None of these parameters are environmentally qualified, but otherwise no change is required.

Variables Emergency Coolant Type: D Water Storage Tank Invel Range: Top to hottom Diablo: Approx. top to bottom No change required.

Variables Condensate Storage Tank Type: B, C Level Ranger Plant Specific Diablo: Approx top to bottom our indication is not redundant, and is not safety grade, but it is seismically qualified. It is continuously indicated, but not recorded. The addition of a redundant transmitter with recorders could be done if we could use the same taps on the tank. This would encounter the control board location problem described in the general comments.

Variable: Accumulator Tank Level Type: D Range: Tbp to botton. Diablo: Tech. spec. range (narrow)

Our existing transmi:ters cannot be extended in range without affecting accuracy and thus tech spec. requirements. New transmitters could be added to the existing taps which cover the range from tangent to tangent. Because the top and bottom are domes, and the center section is relatively short, this only covers about one half of the volume. Inlet and discharge lines on the top and bottom of the tank could be tapped to provide wide range indication.

Variable: Accumulator Isolation Type: D Valve Position Range: Closed-not closed. Diablo: Closed-open The position switches are not environmentally qualified, but otherwise no change is required.

-10B-Variable: RHR Heat Exchanger  ?/pe D Outlet Temperature component cooling water temperature Range: 320 F to 3500 F Diablo: 50 0F to 400 0F The transmitters are not environmentally qualified, but otherwise no change is required.

Variable: Ultimate Heat Sink Type D Loop Flow Range: 0-1101 of Design Diablo: None This would be an extremely difficult, if not impossible, paramete; to retrofit. The auxiliary saltwater piping is buried 24 inch "paralined" carbon steel pipe. We do have a traverse point for testing where an annubar is used to test the flow. Although this could be permanently installed, our experience with annubars is such that we fear leaving them in line to break off and catch in something downstream.

Variable: Ultimate Heat Sink Loop Type: D Temperature Range: 300 F to 1500 F Diablo: 0-130 F This is presently a local indication. Taking it to the control room is feasible. Our main discharge temperature monitoring system does read out in the control room, but it does not reflect the auxiliary saltwater temperature due to the huge flow ratios. Since our heat sink is the ocean, this parameter is not very important anyway.

Variable: Ultimate Heat Sink Level Type: D Range: Plant Specific. Diablo: lbne Our ultimate heat sink is the Pacific Ocean. Level measurement is not applicable.

-llB-Variables Heat Removal by Containment Type B Fan Coolers Ranges Plant Specific. Diablo: See below No continuously recorded c.athod exists for discerning the amount of heat removed by the containnent fan coolers. We have a manual system whereby the operator drains the tail pipe, isolates, and times the rise in tail pipe.

This determines the amount of condensate removed by the fan cooler, and is all done f rom the control room at a switch module. The feasibility of measuring the heat removal is a function of the sophistication required.

Variables Boric Acid Charging Flow Type: B Range 0-110% of desig1 flow Diablo: 0-100% of max. flow Presently, this flow rate is not recorded, is not redundant, and is not environmentally or seismical:.y qualified. The piping would have to be reconfigured to put in a redundtnt flow transmitter. Adding recorders is feasible but subject to the location problems on the main control board described previously. Seismic qualification can be accomplished easily enough; there is nothing likely to fail in a seismic event. Environmental qualification could be very difficult.

Variable: Sump Levels in safety equipment Type: D Range As appropriate. Diablo: See below.

Most equipment is in rocms which have drain pipes large enough to handle flood conditions. Ib sumps are provided. In those rooms where sumps exist, there are high alarms for the sumps, but no level indications.

Addition of level indication is quite feasible, but we feel its value is not sufficient ts justify the additional control board clutter it would generate.

Variables High Level Radioactive Type: E Liquid Tank Level Range: Top to bottom. Diablo: Approx. tcp to bottom No change rJguired.

-12B-Variable: Radioactive gas Type: E holdup tank pressure Range: 0-150% of design Diablo: 0-100% of desig The design pressure of the tank is 150 psig. The maximum output pressure capability of the compressors is 110 psig. The transmitters are pneumatic and don't indicate in the control room. Addition of control room indication is feasible, but the loop would have to be totally re-designed.

Variable : Emergency Ventilation Type: D Damper Position Range Open-close status Diablo Open-close status The status lights are in the ventilation room above the control room with alarm in the control room if the dampers are not properly aligned.

Putting all of the status lights in the control room would require the use of large amounts of space not currently available.

Variable: Safety Equipment Space Type: D Temperature 0

Range: 30 F to 180 F Diablo: Area dependent The readout is not in the control room, but in the cable spreading room. A high alarm in the control room indicaces that the design temperature of the equipment has been exceeded in an area. Readout in the control room could be added.

Variable: Status of Class IE Power Type: D Supplies Status of Ibn-IE Power Type: E Supplies Range Voltage and current. Diablo Voltage and current Ib change required.

-13B-Variable: Area Readiation where Type: E access is required.

Range: 10-1 to 104 P/hr. Diablo 10-1 to 104 mP/hr.

3

'Ihis is a factor of 10 above our existing monitors. Such nonitors could be added given the space in the control room if this high a range would be required. We would not wish to re-range our existing monitors since the mP/hr.

range is much more useful for personnel access considerations.

Variable: tbble Gas Effluent Type: E Radiation Range: 10-7 to 10-5 pCi/ce. Diablo: 10-7 to 10- ,#C1/cc (being added) tio change required.

Variable Radio Halogen & Particulate Type: E Effluenc Fadiation.

- Range: 10-3 to 10 2 Ci/cc (sample) . Diablo: 10-3 to 102 aCi/cc (being added)

!;o change required.

Variable Environs Radiation Type: E Exposure Rate Range: 10-6 to 102 R/hr. Diablo: 1;one Although we consider 16 monitors to be excessive for a coastal plant with land in an arc of only 180 , this is indeed feasible to provide at some expense.

Due to the previously stated space considerations, we would avoid a control room readout at all costs.

Variable : Environs Radioactivity Type: E Halogens and Particulates

-9 Range: 10 p Ci/cc to 10-3fyCi/cc. Diablo None Although the number of points is excessive for a coastal plant, this is feasible to monitor.

-14B-

, Variable: Plant and Environs Type: E Radioactivity (portable)

Pange: 10-1 to 104 R/hr. Diablo: Multiple 100 channel MCA lb change required.

Variable: Samples - Primary Coolant, Type: E Containment Air, Sumps samples of primary coolant and containment air exist. We don't presently sample sumps, but we do have the capability to sample the pumped effluent frcm some sumps. Feasibility would be dependent on the sumps to be sampled, and whether or not pumped effluent could be nonitored.

Variable: Analysis Capability Type: E

1. Ga=ma Pay Spectrum

2. pH

3. Hydrogen

4. Oxygen

5. Boron No problems.

Variable: Wind direction Type: E Pange: 0-360 0 Diablo: 0-360 0 lb change required.

Variable: Wind Speed Type: E Range: 0 to 67 MPH Diablo: 0-100 MPH No change required.

Variable: Temperature Type: E Range: -600 F to 120 F Diablo: 0-120 F We feel that this is adequate for a California coastal plant.

} -

-15B-Variable: Vertical tcmperature Type: E difference Ranges -9 F to +9 F Diablo: -60F to +18 F (recorded)

Full tetperature range aPability (indicated)

No change required, Variable: Precipitation Type: E No change required.